Blog

By Don Buehler

I worked for GE Aviation for 25 years, and had many dealings with GE’s unions during that time.  Needless to say, the relationship between those unions and GE management was lukewarm – at best.  It’s no surprise that there was often mutual distrust on both sides.  One of the results of this was often a breakdown in communication.

Both DDTC and BIS recognize the importance of employee communication in a company’s Export Management and Compliance Program. One of their suggestions is to have an anonymous reporting tool, which allows employees to report problems or suspected violations without disclosing their names.  (See Page 58 of the BIS Guidance for more on this recommended best practice.)

I believe that it’s never a bad idea to give employees a process by which they can advise company management on situations anonymously.  Even in the best scenarios (where there’s a great relationship between management and employees), you’ll find that some folks are hesitant about raising problems and issues that can be viewed as “bad news.”  However, as all good managers know, the “bad news” is exactly the kind of news a company needs to focus on and improve, if it hopes to succeed!

Some companies are concerned about the difficulties of responding to anonymous reporters.  One way to resolve this issue is to post resolutions to the issues raised on your company’s intranet.  Other ideas include reviewing the situations during staff meetings or including updates in your company’s regular export compliance training.

So, should your company adopt an anonymous reporting tool?  Weigh the pros and cons and make a decision based on your company culture and the relationship between management and employees.  Whatever tools help to engage your employees in maintaining and improving your compliance process and program is a positive thing for your Export Management and Compliance Program.